Sofia Yablonskaya

“The published lists contain no separate entries for successive general-purpose model generations at the five frontier AI labs examined here. This finding is primarily about the lack of public visibility, but it cannot be inferred that the new models were not reviewed.”

“The framework describes the possibility that models could strategically lower their performance in evaluations, conceal actions, or exploit flaws to break isolation restrictions and access external systems.”

“For frontier AI governance, recognition of the risks is distinct from evidence that labs are required to manage them. Framework 3.0 provides the former. Whether its provisions acquire practical force through regulators, standards, courts or company practice is the question for the implementation tracker.”

“The opinion focuses on preventive measures and technical feasibility, and also provides conditional protection for some open-source code providers, but it does not itself establish duties related to the loss-of-control risks mentioned in Framework 3.0.”

“For the incident channel to be useful, the next round in November would need to clarify terms such as “incident” and “frontier model”: Will the channel cover internal models, or only commercially released “services”, to which most Chinese AI regulation is currently limited?”